The High Court clarifies that a petition seeking quashing of an FIR becomes infructuous if the petitioner is acquitted during its pendency. This order affirms established procedural principles and carries binding authority on subordinate courts in Chhattisgarh regarding the disposal of similar quashing petitions following acquittal.
Summary
| Category | Data |
|---|---|
| Case Name | CRMP/413/2020 of SATYENDRA KUMAR SINGH Vs STATE OF CHHATTISGARH |
| CNR | CGHC010032332020 |
| Date of Registration | 07-02-2020 |
| Decision Date | 15-10-2025 |
| Disposal Nature | INFRUCTUOUS |
| Judgment Author | Hon’ble Shri Ramesh Sinha, Chief Justice |
| Concurring or Dissenting Judges | Hon’ble Shri Bibhu Datta Guru, Judge |
| Court | HIGH COURT OF CHHATTISGARH AT BILASPUR |
| Bench | Hon’ble Shri Ramesh Sinha, Chief Justice and Hon’ble Shri Bibhu Datta Guru, Judge |
| Precedent Value | Binding on subordinate courts in Chhattisgarh |
| Type of Law | Criminal Procedure |
| Questions of Law | Whether a petition for quashing of an FIR remains maintainable after the petitioner is acquitted in the criminal trial. |
| Ratio Decidendi |
The court reasoned that once the petitioner has been acquitted in the criminal matter arising from the FIR, the petition to quash the said FIR no longer survives and is rendered infructuous. Accordingly, the court dismissed the quashing petition as having become infructuous. The decision affirms the procedural conclusion that judicial relief, having lost its efficacy due to supervening events (i.e., acquittal), cannot be granted. This maintains established principles regarding maintainability and mootness in criminal writs and petitions. |
| Facts as Summarised by the Court | The petitioner sought quashing of FIR No. 37/2020 registered at P.S. Basantpur, District Rajnandgaon. During the pendency of this petition, counsel for the State informed that the petitioner had been acquitted in the trial arising out of the said FIR. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Chhattisgarh |
| Persuasive For | Other High Courts and criminal benches |
What’s New / What Lawyers Should Note
- Reinforces that quashing petitions become infructuous upon the acquittal of the petitioner in the corresponding criminal case.
- Counsel should verify the current status of trial proceedings before pressing for FIR quashing — a subsequent acquittal renders such petitions moot.
- Courts will dismiss quashing petitions as infructuous in similar factual situations.
- Emphasizes procedural prudence: applications seeking relief that has been effectively overtaken by trial outcomes will not be entertained.
Summary of Legal Reasoning
- The petitioner filed a petition under Section 482 CrPC seeking quashing of an FIR.
- The State informed the court that, during pendency of the petition, the petitioner had been acquitted in the trial.
- On consideration of this supervening event, the court noted that the foundational prayer for quashing the FIR did not survive.
- It held that, since the petitioner had already secured acquittal in the criminal case, the petition was rendered infructuous.
- Consequently, the petition was dismissed on the ground of infructuousness, applying established principles regarding loss of cause of action.
Arguments by the Parties
Petitioner
- Not specified; petitioner/counsel not present at hearing per order text.
Respondent / State
- Submitted that the petition has become infructuous due to the petitioner’s acquittal in the relevant criminal case.
Factual Background
The petitioner filed a criminal miscellaneous petition seeking quashing of FIR No. 37/2020 registered at Police Station Basantpur, District Rajnandgaon, Chhattisgarh. During the pendency of this petition, the State informed the court that the petitioner had been acquitted in the matter arising from the said FIR. In view of this development, the State contended—and the court accepted—that the petition was infructuous.
Statutory Analysis
- The judgment applies principles of procedural law concerning maintainability and infructuousness of petitions.
- Section 482 CrPC: No substantive discussion or interpretation provided in the text regarding the scope or application of inherent powers beyond their procedural implication—i.e., the petition did not survive after acquittal.
Alert Indicators
- ✔ Precedent Followed – The order reaffirms established procedural principles regarding disposal of moot or infructuous petitions after acquittal.